Pacific Development, Inc., was incorporated in

the District of Columbia in 1968 to engage in the business of

international brokerage and consulting. Tongsun Park was Pacific's

founder, president, and sole shareholder. It was doubtful whether

Pacific had a board of directors prior to December 1974. The directors

met infrequently after 1974. When they did meet, they approved

without discussion or question corporate decisions made by Park. Park

wrotecheckson Pacific's bank accounts to cover his unrelated personal

and business expenses. Pacific employees served as Park's household

servants. Park madeloanswith Pacific funds to politically influential

people and then forgave the loans. Pacific personnel provided

administrative and managerial services for Park's other business

ventures, and Pacific's profits were assigned to Park or to his other

companies. In 1977, the IRS assessed $4.5 million in back income

taxes against Park. Should the court allow the piercing of Pacific's

corporate veil in order to pay the back-income taxes? Explain why or

why not.